Put A Bird On It, LLC v. Seattle Arena Holdings, LLC
Washington Court of Appeals, Division One · Wash. Ct. App. · Washington bar guidance
Verified May 14, 2026
- Citation
- Put A Bird On It, LLC v. Seattle Arena Holdings, LLC, No. 87756-9-I (Wash. Ct. App. Div. I Mar. 2, 2026) (Feldman, J.)
- Decided
- March 2, 2026
Summary
Appellant's counsel at Corr|Downs PLLC filed an opening brief in this contract appeal whose citations the responsible attorneys later acknowledged had been generated by "AI-based search engines." The opinion, authored by Judge Leonard Feldman with Judges Lori Smith and Janet Chung concurring, describes the offending references as combining "a real or fictitious caption, citations to other entirely different cases, and legal principles that cannot reasonably be found in the cited cases." The court flagged the conduct in a footnote rather than in a separate sanctions order. The substantive appeal, an effort by Arrowfish Concepts to revive contract, promissory estoppel, and related claims arising from negotiations over a Seattle arena project, was affirmed on CR 12(b)(6) grounds.
- AI tool:
- AI-based search engines (unidentified)
What sanction did the court impose?
Affirmance of the trial court's CR 12(b)(6) dismissal with prejudice. No monetary sanction, no RAP 18.9 fees, and no bar referral. The panel publicly admonished Corr|Downs PLLC in a footnote, observing that the conduct "falls below our expectations of counsel," and noted that the firm had apologized, taken remedial steps, and implemented quality-control protocols.
Why does Put A Bird On It, LLC v. Seattle Arena Holdings, LLC matter for law firms using AI?
Put A Bird On It is a useful counterpoint to the federal sanctions cases: a state appellate panel can publicly name the firm in a published opinion, decline any monetary penalty, and still inflict significant reputational cost on the lawyers involved. For a managing partner at a 5-50 attorney firm, the lesson is that the downside of an AI-generated citation is not bounded by Rule 11 dollars. A footnote in a Westlaw-indexed Washington appellate decision now permanently associates the firm with fabricated authority, regardless of remedial training adopted after the fact.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.